Application for declaratory order and review of Second Respondent's decision to impose penalties in terms of Section 40 (1) of the Income Tax Order 1975-Applicant alleging that decision by functionary is unlawful and liable to be set aside on reviev.1. Respondents arguing that Applicant liable to pay additional tax and/or penalties on account of failure by the latter to file income tax returns for the 2020 and 2021 financial years on time.